Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for 1956 in the amount of $8,470. The only issue for decision is whether an amount of $20,000, which was stated in an agreement involving a sale of the business of Packers Express, Inc., to be for one of petitioners' refraining for a period of 3 years from engaging in the trucking business within the territory in which the business sold was...
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